NawrasP.O. Box 874P.C . 1 1 1Centrat Post OfficeSuLtanate of OmanTet: +968 2200 2200Fax: +968 2200 2299

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OMANI QATARI TELECOMMUNICATIONS COVPANY S â 0,G.C.9. No. 1/77152/3

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Muhammed SaeedActing Senior ManagerEconomic Affairs UnitTetecommunications Regutatory AuthorityP0 Box 579Ruwi 1 12Suttanate of Oman

Our Ref: JM/JT/ 3 %. Q P- /201 1

24 September 201 1

Dear Muhammed,

Re: Public consultation on ''Draft Code of Practice on Tariff Transparency''

We refer to your tetter dated 21 August 201 1 (ref: TRA/ECON/ 161 /9803/201 1 ) with the abovementioned subject.

Kindty find enctosed our feedback regarding the same.

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the opportunity for further discussion with the TRA on the abovementioned

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TM 's Public Consultation on Draft

Code of Practice on Tariff

Transparency

Naw ras' response

24 Septem ber 201 1

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1 Executive Sum m ary

1.1 Introduction

We thank the TRA for conducting this consuttation and for giving Nawras anopportunity to provide comments on this important topic.

Nawras supports the idea of transparency in tariffs în order to protectbeneficiaries. We think this is a highty appropriate objective for the industryand in practice it is something that Nawras atready strives to achieve.

We trust that the TRA finds our comments usefut and we woutd wetcome theopportunity of further discussion with the TRA regarding this issue. We woutdatso encourage the TRA to continue its diatogue with the industry and tocircutate further comments for consideration after the TRA has assessed theresponses it receives to this consuttation.

1 .2 Summary of key points

We set out in section 2 betow our detaited comments on the suggested code.We respectfutty put forward our main points:

Additionatty, we atso make the fottowing generat observations regarding thisissue:

(a) we consider that it woutd be good for the TRA to exptain the tegat basisfor the proposed code and how it witt tînk to the current taws andregutations and operator ticences;

(b) the provision of sufficient and accurate information by operators needsto be comptimented by a raising of the generat awareness of consumersthrough industry education campaigns initiated by the TRA; and

the principtes of tariff transparency need to be imptemented within anenvironment that atso encourages operators to detiver innovativeproducts and services with taitored and sophisticated tariff options;and

(d) we consider that the TRA shoutd move to a system of ex-post regutationon tariff approvats and that the imptementation of codes of practicetike that proposed here, are a naturat comptement for such a move.

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2 Detailed com m ents

2.1 In generat, we have no objection to the draft Code. We kindty putherewith some comments, in particutar to the fottowing sections on theCode:

Section 2. 1. Duty to disclose Price Limitations, Terms and Conditions

We agree with the TRA that it is important that customers have easyaccess to the terms and conditions of their selwice and that att keyterms retating to their service are disctosed to them.

It is our view that the current practice of making terms and conditionsof services avaitabte at the point of purchase, through the internet andthrough customer service is sufficient in this regard. We consider thatthe current practice is working wett and therefore shoutd not bemateriatty changed in the absence of competting reasons. If the TRAhas such reasons we kindty request that the TRA provide those

In retation to opting in to a service, we consider that it is onerous torequire customers to specificatty accept the ''vatidity period'' inisotation to att terms and conditions. We consider that a generatacceptance is sufficient provided that the customer has easy access toretevant terms and conditions inctuding vatidity period.

It is atso worth noting that the suggested SMS respond woutd onty apptyto mobite subscribers and does not consider fixed tine users.

In retation to corporate customers we consider that it is not necessaryfor tariffs to be pubtished because this has the potentiat to hampercompetition between operators and atso because we consider thatgeneratty corporate pricing can be teft to the market without the needfor regutatory intervention. It is our humbte opinion that suchinformation may be provided for corporate customers and/or potentiatcorporate customers on a case by case basis. This practise is widetyadopted in the region as wett as internationatty.

Section 2. 1 .5 yonitoring the usage

Itemized bitting can be submitted upon request.

We suggest to the TRA that instead of prescribing specific informationrequired to be presented, which may not be retevant to every selwice,the TRA coutd take a broader view and simpty ensure that serviceproviders present att relevant or material information regarding thetariffs and for the information to be ctear and readity accessibte.

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Section 2.3.2 TI/I'fJJ options with inclusive time or credit

It may not be feasibte to mention atL the information tïsted on the Codeon att ''pubtications'' and certainty not on outdoor or newspaperadvertisements. It is our view that provided such detaiLed information ismade avaitabte to consumers prior to the time of purchase, consumerprotection has occurred.

We agree with the TRA that comprehensive information shoutd beavaitabte through muttipte channets inctuding stores, websites and/orcatt centres, as is the current Nawras' practice.

Section 4. Service Term ination or Suspension

We agree with the generat idea that the tegaL obtigations of bothparties need to be respected. In the absence of any faiture by an

operator to compty with tegat and regutatory requirements (inctudingthose proposed in the Code) then contractuat commitment shoutd behonoured by both parties, inctuding any termination tiabitity.

In reference to the requirement for the Licensee to compensate thebeneficiary for any outstanding payment, this is correct and is a tegatrequirement. The amount to be paid to the beneficiary woutd need tobe determined after taking into consideration any requirement for thebeneficiary to pay any outstanding charges inctuding any terminationretated charges.

We raise again our generat position in retation to corporate customers,which is that they require tess regutatory intervention/protection andsuch intervention/protection, has the tendency to stifte corporateactivity rather than assist it. This principte of treating consumer andbusiness differentty from a regutatory perspective is widety adopted inthe region as wett as internationatty.

Section 5. 1 yobile Number Portabilit;

We agree with TM 's sentiment in terms of raising awareness tobeneficiaries when making off-net catts. The first proposat made by theTRA is the easiest and the best and is consistent with current practice.The second and third options are cumbersome and expensive and tiketyto resutt in increased costs for the industry. Further, it is ourexperience that this issue is not significant. If the TRA hotds a contraryview we woutd weLcome receiving from the TRA its experience as wetLas some evidence of the extent of the perceived probtem .

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We hope the TRA finds our detaited comments in section 3 usefut. We atso hopethat the TRA witt take into consideration the fottowing generat points regardingthis topic:

Conclusion

we consider that it woutd be good for the TRA to exptain the tegat basisfor the proposed code and how it witt tink to the current Laws andregutations and operator ticences;

(b) the provision of sufficient and accurate information by operators needsto be comptimented by a raising of the generat awareness of consumersthrough industry education campaigns initiated by the TRA;

the principtes of tariff transparency need to be imptemented within anenvironment that atso encourages operators to detiver innovativeproducts and services with taitored and sophisticated tariff optïons;and

we consider that the TRA shoutd move to a system of ex-post regutationon tariff approvats and that the imptementation of codes of practicetike that proposed here, are a naturat comptement for such a move.

We woutd wetcome the opportunity of further discussion with the TRAregarding this issue and we are avaitabte to answer questions or provide furtherinformation if requested.